- 29 - cattle breeding activity where no cattle inventory records kept). Similarly, with respect to the financial ledgers for Maple Row maintained by Mrs. Burrus, we find that these records, though not flawless, represented a reasonably accurate attempt to record the activity’s financial results. Moreover, petitioners maintained separate bank accounts for the purpose of conducting Maple Row’s affairs. When cash was transferred from personal or other accounts to Maple Row’s accounts, the transfer was recorded in the ledgers. Cf. id. (no separate bank account for cattle activity). Respondent’s expert postulated several criteria to which he believed a profit-oriented purebred cattle breeding operation would adhere, and found Maple Row’s practices at variance with those criteria. To the extent the expert’s testimony was intended to show that petitioners conducted their cattle breeding activity in a manner not substantially similar to like activities conducted for profit, we are unpersuaded. Respondent’s expert cited the need for genetically superior stock, but then opined merely that he was unable to determine from the records provided him whether petitioners had such stock. In this regard, it is worth noting that the expert cited in his report petitioners’ documentation to the effect that Maple Row had received the designation “1998 Top Recorders in Tennessee” for havingPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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